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assistance that it would otherwise provide. FEMA applicants will be best served by such donors if the donor provides the recipient with a letter indicating that the funding is for certain specific purposes. For instance, an Irene survivor receive a donation from a private foundation to compensate her for losses related to the destruction of the inventory of her small business located within her home. This donation was not a duplicate benefit because it covered losses not allowable under IHP.


Where an application is denied because the disaster victim has not applied to SBA


(i.e., the applicant had the opportunity to access an alternative funding resource but opted not to do so, so duplication has been implied), if the applicant is low-income, you may be able to resolve the issue without a formal appeal. In such cases, a call to the FEMA Service Center at 800-621-FEMA to point out that the applicant’s only income is Social Security, for example, may suffice.


Ineligibility Based on Program Requirements Where program eligibility requirements are allegedly not met, appeals involve


providing as much evidence and documentation as possible to show that the applicant satisfies eligibility requirements. After Irene, some tenants were surprised to find their FEMA applications denied because of the shared household rule. Their landlords had already applied for benefits, falsely claiming to be occupants in the property rented out to the tenant. To appeal such a denial, the tenant would provide a copy of her lease, cancelled rent checks, show utility bills in her name, and legal records (tax form, driver’s license, etc.) listing her address.


Insufficient Documentation of Losses or Disputes as to the Value of Losses The applicant should provide as much evidence and documentation as possible to


show the costs the applicant has or will incur due to the disaster. The applicant will need to obtain a copy of her FEMA file to see how much funding FEMA has allotted for each type of repair needed. The applicant can contest FEMA’s estimates by demonstrating that the estimates for repairs FEMA has used in its calculation are too low or by showing that FEMA has applied the wrong type of repair to the homeowner’s problem. For instance, in one Irene case, a homeowner’s septic system failed due to the flood. FEMA included an estimate for a leach field system, but the homeowner’s property would only support a mound system. With a report from a licensed septic system designer, the applicant was able to obtain additional funding to repair the system. In most cases, however, the applicant will be required to produce at least two estimates from licensed contractors, electricians, plumbers, or other repair persons.


In a very limited number of cases, the applicant may appeal for home replacement


value rather than home repair value. This is particularly appropriate in cases involving damage to a mobile home. Mobile homes are rendered structurally unsound with even slight shifts of their cement blocks. The cost of repairing the flooring, walls, electrical system, and insulation in a mobile home inundated with as little as 3 inches of water will usually not be financially reasonable given the trailer’s pre-disaster value. To appeal for


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